NYSDA Publications

Centers for Medicare and Medicaid Services (CMS) Issues Open Payments Program Updates

Sep 30, 2025

Program Year 2026 Teaching Hospital List

The Open Payments Program Year 2026 Teaching Hospital List is now available on Open Payments Resources for Reporting Entities page.  The teaching hospital list identifies which teaching hospitals are considered covered recipients and are reportable in Program Year 2026.  This list should only be used for Program Year 2026, which is data collected from January 1, 2026, through December 31, 2026.  Teaching hospital lists for previous program years are also available on the Open Payments Resources for Reporting Entities Page.

Program Year 2026 Reporting Thresholds

The Open Payments Key (de minimis) Thresholds for reporting have been adjusted based on the Consumer Price Index.  Small payments or other transfers of value of less than $13.82 do not need to be reported, except when the total annual value of payments or other transfers of value to a covered recipient exceeds $138.13 for Program Year 2026.  These amounts only apply to Program Year 2026, which is data collected from January 1, 2026, through December 31, 2026.  You can access the Key (de minimis) Thresholds on the Open Payments Data Collection page.

Physician and Non-Physician Practitioner Taxonomy List

In preparation for the Program Year 2026 data collection period (January 1 – December 31, 2026), CMS is releasing the PY26 Physician and Non-Physician Practitioner Taxonomy List.  This is available on the Open Payments Resources for Reporting Entities page.

Please note that the taxonomy list only defines the range of accepted values in the Covered Recipient Specialty field in the Open Payments system and does not define the universe of providers considered covered recipients in Open Payments.  Reporting entities must follow the covered recipient definitions provided in the program’s final rule and clarifications in the FAQs when deciding whether an individual provider is reportable.  When reporting on a covered recipient whose specialty recorded in other CMS systems of record does not match any of the specialties on the list, the reporting entity should select an alternative taxonomy code from the list that most closely represents the specialty the provider practices with as it’s known to the reporting entity.

General Reminders

Post - Deadline Submission

If you have reportable payments or other transfers of value from Program Year 2024 or prior that have not yet been reported to CMS, those records must be submitted immediately upon confirmation of the error or omission (see 42 CFR §403.912(h)).  This means that if your organization has not submitted all of its required records, your reporting entity should do so as soon as it is able.  CMS recommends using the assumptions document to communicate your organization’s methodologies or any circumstances for unusual reporting, such as records that are attested after the submission window.  Assumptions are documented in a free-form text field during the attestation process and are not made available to the public.

Record Resubmission

When making changes to records some may need to be deleted and re-uploaded, while other changes only require resubmission.  If fields that identify the record’s covered recipient or principal investigator(s) need to be changed in a record that is in a “ready for attestation” or “attested” status, the original record must be deleted and then re-submitted as a new record.  Deleting records and submitting new records will remove the original records from publication and will make the newly submitted records eligible for review and dispute again.  The attester is encouraged to use or amend the assumptions statement to note when records have been deleted and re-submitted, including if or when those records were re-submitted after the submission deadline.  Records that are deleted need to have a reason for deletion included, and records that are deleted and resubmitted need to be linked to the deleted record.

Need Help or Have Questions?

For more information about Open Payments, please visit the Open Payments website.  If you have any questions, you can e-mail the Open Payments Help Desk at: openpayments@cms.hhs.gov.  Live Help Desk support is available by phone at 1-855-326-8366, (TTY Line: 1-844-649-2766) Monday through Friday, from 9:00 a.m. to 5:00 p.m. (ET), excluding Federal holidays.